SENATECH INDIA PRIVATE LIMITED,GAUTAM BUDHA NAGAR vs. DCIT TP 3(2)(2), DELHI

ITA 7827/DEL/2025Status: DisposedITAT Delhi19 August 2026AY 2020-2115 pages
AI SummaryAllowed

What were the facts?

The assessee failed to furnish a transfer pricing study report and other required documents to the Transfer Pricing Officer (TPO) despite multiple notices. A penalty under Section 271G was levied for this non-compliance. The assessee argued that the notices were ambiguous and the TPO did not have adequate time to review the report when it was finally submitted.

What did the Tribunal hold?

The Tribunal held that the penalty notice issued under Section 271G was ambiguous as it did not specifically mention the documents or information required under Section 92D that were not furnished. Furthermore, when a specific notice under Section 92D(3) was issued, the assessee complied by submitting the transfer pricing report.

What were the issues?

Whether the penalty levied under Section 271G for failure to furnish information/documents under Section 92D is sustainable when the notice is ambiguous and the assessee subsequently complies with a specific notice.

Which sections of the Income-tax Act were involved?

Section 92D,Section 92CA,Section 271G,Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “H” BENCH, DELHI

Before: SHRI RAMIT KOCHAR & SHRI ANUBHAV SHARMA

For Appellant: CA Sh. Antik Majumdar, Adv
Hearing: 28.07.2026Pronounced: 19.08.2026

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the assesse against the order dated 19.09.2025 of the Ld. National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld.

P a g e | 2 Senatech India Pvt. Ltd. (AY: 2020-21) ‘FAA’) arising out of the order dated 29.03.2024 u/s 271G of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by AO, Assessment Unit, for AY: 2007-08. 2. Heard and perused the record. The assessee’s return of income was selected for complete scrutiny and a reference was made to Transfer Pricing Officer (TPO) f

The order continues below.

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